Free Affidavit - District Court of Delaware - Delaware

Case 1:04-cv-00834-SLR Document 18 Filed 05/18/2005 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE

In re: I Chapter ll
I
STONE & WEBSTER, INCORPORATED I Case No. 00-02142 (PJW)
gt gl., I Jointly Administered
I Adv. No. 0l·—7766 (PIWI
Debtors I
_..__........____..._..._..2.,..._..._I
I
SAUDI AMERICAN BANK, I
Plaintiff I
I
v. I
I
THE SHAW GROUP INC., SWINC I
ACQUISTION THREE, INC., and I
STONE & WEBSTER ENGINEERING I
CORPORATION, et al., I
Defendants I
__.___._.__m__M....._......_.L...._.__.....-.I
AFFIDAVIT OF JOHN C. HUTCHINS IN SUPPORT OF
PLAINTIFF’S MOTION FOR ASSESSMENT OF DAMAGES
I, John C. Hutchins, do hereby depose and state:
l. I am a partner in the law firm of Kirkpatrick & Lockhart Nicholson Graham LLP
("K&LNG"I, counsel for the plaintiff, Saudi American Bank ("SAMBA") in the above captioned
action. This affidavit is made in support of Plaintiff ’s Motion for Assessment of Damages and
Memorandum in support thereof, which are being filed herewith.
2. I am familiar with the facts surrounding this case, I have supervised K&LNG’s
representation of SAMBA in the bankruptcy proceedings and I have assisted in the litigation of
this matter from the outset.
Bos-847207 vl ososszo-0901

Case 1:04-cv-00834-SLR Document 18 Filed 05/18/2005 Page 2 of 2
3. I have reviewed and am fully familiar with all of the K&LNG billing items
referred to in the Affidavit of Daniel E. Rosenfeld and attached as Exhibits A and B thereto.
4. Each item that is included in the Affidavit of Daniel E. Rosenfeld and attached as
Exhibits A and B thereto is, in my judgment, which is based on my substantial legal experience:
(1) a reasonable and necessary expense; (2) does not include any expenses that were
unnecessary, redundant, or excessive; (3) was calculated using hourly rates and fees that are no
greater than K&LNG’s customary fees for cases of this type; and (4) is the amount that has been
or will be charged by K&LNG to SAMBA in connection with this litigation.
Signed under the pains and penalties of perjury this day of May 2005.
1/
ry ly
/t»~.»~ .» I /Lc//kw/S _____
J hn C. Hutchins
l
CQMMONWEALTH OF MASSACHUSETTS
Suffolk, ss. Date: @1
., ' '
On this U day of , 2005, before me, the undersigned
notary public, personally appeared (\. Og , proved to me through
satisfactory evidence of identification, which was }l?;f`g`§ OW] , to be
the person whose name is signed on the preceding or attached document in my presence.
()ilil’l(i lll, tiu¢i.%g»»/ Wi l` ( ii _
~l>iIotary Public for (
the Commonwealth of Massachusetts M
· - · rrgp; lm ¤‘ Q/`l’)B
My commission expires, i, . il .t2l_}__ A lt
Gll\!A M. HTZGERALD. NOTARY PUBUC
rv rmt/1NllSSl0N EXPlHES JANUARY 31, 2008
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